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Mitchell D. Roth <br />Mayor <br />Lee Lord <br />Managing Director <br />County of Hawai'i <br />VEP,42XIMIT OF FUVI?,0I&A4f_IlTAI UMP102�lk <br />345 Keki)anao'a Street, Suite 41 - Hilo, Hawai'i 96720 <br />Ph: (808) 961-8083 - Fax: (808) 961-8086 <br />Email: cohdem@hawaiicounty.gov <br />May 24, 2021 <br />Mr. Jelani Shareem <br />EPA Region 9 Compliance Officer <br />75 Hawthorne Street <br />San Francisco, CA 94105-3901 <br />(Via E-mail: shareem.jelani@epa.gov <br />Ms. Kate Rao <br />EPA Region 9 LCC Project Coordinator <br />75 Hawthorne Street <br />San Francisco, CA 94105-3901 <br />(Via E-mail: rao.kate@epa.gov) <br />Ramzi I. Mansour <br />Director <br />Brenda lokepa-Moses <br />Deputy Director <br />SUBJECT: Request for Change to Compliance Milestone for the P5hala Wastewater <br />Treatment Plant and Collection System <br />Federal Administrative Order on Consent <br />EPA Docket No. SDWA-UIC-AOC-2017-0002 <br />P5hala Large Capacity Cesspools (LCC) <br />Dear Mr. Shareern and Ms. Rao: <br />The State of Hawai'i's historic preservation process (established under Chapter 6E, Hawai'i <br />Revised Statutes) comprises a multi -step consultation and review system with the State Historic <br />Preservation Division (SHPD). The process has proven to be cumbersome on the Pdhala project <br />resulting in significant uncertainty and delays. <br />The draft Pdhala archeological inventory survey (AIS) was approved by SHPD on February 20, <br />2020. A copy of the approval letter is attached for reference. SHPD requested that the AIS <br />document be finalized and submitted to SHPD. The final AIS was completed and submitted on <br />April 24, 2020. <br />Then SHPD required the preparation of an archeological monitoring plan (AMP) as a condition <br />of the AIS approval. A draft AMP was submitted to SHPD on May 5, 2020 and was <br />subsequently approved by SHPD on November 4, 2020 (attached). <br />County of Hawaii is an Equal Opportunity Provider and Employer <br />